EPA: Its Role and Product Registration
Editor’s note: I have always been confused as to what the EPA is supposed to do and what EPA registration on a product means. Stan Halpern, an Environmental Cleaning Consultant,from Healthy Clean Buildings,straightened me out recently. I hope this clears up any confusion for you too.
- What is the EPA’s role in registering ‘environmentally-safe’ products?
- What is the purpose of the EPA?
- What about Product Registration?
- So what does Biodegradable mean?
- What are environmentally preferable products?
- What are the criteria for Environmentally-Preferable cleaning programs?
I am never quite sure what the EPA mean by ‘environmentally-safe’ since I bought one product that was EPA registered and it could kill you if you had direct physical contact! Since a number of people who we cater to have MCS in a mild or severe form – my rule of thumb is if you can ingest it and not be sick then it should be OK!
A.Let me clear this confusion up for you… The U.S. Environmental Protection Agency was established as an independent federal agency on December 2, 1970. It’s mission is to protect human health and to safeguard the natural environment–air, water, and land–upon which life depends. This agency (EPA) endeavors to accomplish its mission systematically by proper integration of a variety of research, monitoring, standard-setting, and enforcement activities. As a complement to its other activities, EPA coordinates and supports research and anti-pollution activities of State and local governments, private and public groups, individuals, and educational institutions. EPA also monitors the operations of other Federal agencies with respect to their impact on the environment.
A. The EPA’s purpose is to ensure that:
All Americans are protected from significant risks to human health and the environment where they live, learn and work.
- National efforts to reduce environmental risk are based on the best available scientific information.
- Federal laws protecting human health and the environment are enforced fairly and effectively.
- Environmental protection is an integral consideration in U.S. policies concerning natural resources, human health, economic growth, energy, transportation, agriculture, industry, and international trade, and these factors are similarly considered in establishing environmental policy.
- All parts of society–communities, individuals, business, state and local governments, tribal governments–have access to accurate information sufficient to effectively participate in managing human health and environmental risks.
- Environmental protection contributes to making our communities and ecosystems diverse, sustainable and economically productive.
- The United States plays a leadership role in working with other nations to protect the global environment.
Q. What about Product Registration?
A.ANY PRODUCT WHICH MAKES CLAIMS TO KILL ANY LIVING ORGANISMS, such as insects (insecticides), bacteria (disinfectants), algae (algaecides), mold & mildew (fungicides), weeds (herbicides); and so forth, MUST be registered with the federal E.P.A. An E.P.A. registration number has absolutely NO BEARING on being ‘Environmentally-Friendly’ or ‘Environmentally-Safe’ ( especially, in terms of allergies or multiple chemical sensitivities) from product usage IF THE INGREDIENTS OF THE PRODUCT ARE DEEMED LEGAL TO USE BY THIS AGENCY. These pesticides, according to the printed label, indicate the best way to reach, dispose, and apply the registered product against targeted pests. Lets take an example: everyone knows that household bleach is generically 5.25% (by wt.) sodium hyperchlorite. If the bleach product is registered with the E.P.A. (like ‘CLOROX’), it can make claims regarding sanitizing or disinfecting surfaces against (killing) bacteria, according to the label usage, based upon this registration. However, if the bleach product is unregistered with the E.P.A. (such as private label supermarket bleach), it can ONLY make claims of ‘cleaning’ and ‘whitening’ although generically the chemical make-up is exactly the same. Without the E.P.A. registration number on the package, no statements or product performance regarding the lowering of bacterial counts or ‘killing bacteria’ on hard surfaces,’sanitizing’, ‘germicidal’ or ‘disinfecting’ can be made by the same chemically formulated product. This may sound confusing, so here’s an example: A restaurant knows it must sanitize its cooking utensils according to health laws in its daily operations. Bleach is referred to as the ‘universial sanitizer’. The owner purchases ‘the cheap’ bleach off the supermarket shelf without an E.P.A. registration number for such purpose. Weeks later, a Board of Health inspector notices this type of bleach being used and fines the restaurant for ‘non-compliance’ of health laws since no sanitizing claims on the label are made by the bleach being used. Although the restauranteur argues that the chemical make-up is the same as ‘CLOROX’, he/she has no recourse with the health authority since an unregistered product cannot make any bacterial ‘kill’ claims… THEREFORE, , AN EPA REGISTRATION NUMBER HAS NO BEARING ON THE TOXICITY OR HAZARDOUS INGREDIENTS OF A PRODUCT. IT JUST MAKES A ‘KILL’ CLAIM OF A LIVING ORGANISM BASED UPON THE INGREDIENTS OF THE PRODUCT AND PROPER USAGE ACCORDING TO LABEL DIRECTIONS. Words like ‘environmentally-friendly’ and ‘environmentally-safe’ are sales and marketing hype terms to make a product SOUND as if it is ‘safe’ and ‘healthy’ to use.
I am sure that you have heard the term 100 percent completely biodegradable.
(the ability of a product to breakdown completely and its component return to the environment without polluting it) Did you know that pure sulfuric acid is completely 100% biodegradable? (not the healthiest or safest of products to have around). Some products making this claim completely biodegrade in 30 years (to the unknowing consumer). With an ‘environmentally-preferable’ product, more than half should biodegrade within 28 days with the balance within a few months after its application to be safe and healthy.
A. Here’s the thorough explanation of the background of ‘environmentally- preferable’: In February 1993, Public Building Services (PBS) of the federal government’s General Service Administration (GSA) began the ‘Cleaning Products Pilot Program’. At that time, the objective was to identify specific ‘ENVIRONMENTALLY-PREFERABLE'( the only viable, legally-binding environmental cleaning chemical term assigned by the federal (and state) governments for products with credentials regarding testing/performance criteria and impact on the environment and health/safety of individuals) cleaning products with reduced health and safety concerns for use in cleaning over 7,000 federal buildings. Up to that date, most of the publicly available environmental information on products consisted of UNSUBSTANTIATED VENDOR CLAIMS OR ‘HOME REMEDIES’ ( with descriptions like ‘Environmentally-Friendly’ and ‘Environmentally-Safe’). PBS officials wished to define and identify’ green’ cleaning products. Product usage was chosen as the key focus for assessment since it was indicative for the greatest direct health risk from the cleaning products to custodial workers to occupants. Consequently, specific environmental attributes were identified to help assess the environmental preferability of commercially available cleaning products (OR THE INACCURATE DESCRIPTION, ‘ENVIRONMENTALLY-SAFE’ which really should be described ONLY as ‘Environmentally-Preferable’ as defined by the federal and state government with such programs.). These attributes are:
- Skin irritation potential
- Chronic health risks from skin and inhalation exposure
- Quickness of ultimate biodegradation
- Accumulation Factor (Bio-Concentration Factor of an ingredient to accumulate into the food chain
- Percentage of V.O.C.(volatile organic compounds) which increases the potential for offgassing
- Amount of product packaging waste
- Presence of ozone depleters
- Dispensing Method in regards to potential exposure to concentrated cleaning solutions
- Degree of flammability
- Amount of cosmetic additives (fragrances and dyes)
- Impact on energy requirements.
These 11 standards and criteria established the ONLY basis for ‘environmentally GREEN preferable’ cleaning products. Presently, there are ONLY 5 states which have a statewide ‘ENVIRONMENTALY PREFERABLE CLEANING PRODUCT’ Purchasing Program (California, Massachusetts, Minnesota, Delaware, Maryland). These states even have more stringent criteria for their definition of ‘environmentally-preferable’ based on the 1993 federal guidelines. The cornerstone of our ‘HEALTHY CLEAN BUILDINGS’ cleaning program-H2Orange2-is the frontrunner in the Massachusetts ‘Environmentally-Preferable’ Cleaning Products Purchasing Program. ALL participating end-users adopting OUR ‘environmentally-preferable’ cleaning program have removed minimally 8 ‘toxic or hazardous’ substances from its cleaning operations or MORE; reduced 90 % of the different amounts of cleaning products used; created a NEW ‘Environmental Guardian’ mindset for administrative, departmental, and custodial staffs towards their indoor work environments (versus the conventional janitor or custodian labels ); and improved cleaning standards through a simpler, easy-to-understand, more practical cleaning program. End-users involved in this program are reporting a minimum of 15% (or better) savings in their cleaning supply budget through the elimination of the multitude and duplication of products previously being used. Additionally, this program addresses controversial indoor environmental issues such as ‘Sick Building Syndrome’; ‘I.A.Q. (Indoor Air Quality); ‘Multiple Chemical Sensitivities’ (MCS); allergic triggers; and other similar ‘ building occupant’ concerns.
Q. What do you suggest are the criteria for ‘Environmentally-Preferable cleaning programs in commercial, school, and public buildings; and homes?
A.‘End-user requires a proven, field-tested ‘HEALTHY & SAFE’ Building Chemical Cleaning System which utilizes a maximum of only 2 chemical components to daily clean an entire facility, or their home. The goals and objectives of this program is to improve indoor air quality and limit building occupants’, especially children’s and custodial worker’s exposure to chemical residues by replacing, reducing, or eliminating existing, conventional, more ‘toxic’ and ‘hazardous’ cleaning chemicals with healthier, safer, and environmentally-sensitive alternatives.’ IN ANY EVENT, ANY CLEANING SYSTEM DEEMED OFFICIALLY ‘ENVIRONMENTALLY-PREFERABLE’ (OR UNOFFICIALLY ‘ENVIRONMENTALLY-FRIENDLY’ -OR-‘ENVIRONMENTALLY-SAFE’) MUST MEET OR EXCEED ALL OF THESE STANDARDS AND CRITERIA
- This system, wherever applicable, MUST be EPA registered as a disinfectant, sanitizer, and/or virucide.
- This system, wherever applicable, MUST be registered with the particular state’s Department of Environmental Conservation as a disinfectant, sanitizer, and/or virucide.
- This system must comply with ALL standards and criteria set forth by the 1993 federal guidelines established by the Public Buildings Service (PBS) of the General Services Administration (GSA) known as the ‘Cleaning Products Pilot Project’ to identify specific ‘environmentally-preferable’ cleaning chemicals with reduced health safety concerns.
- This system must be contracted and accredited as ‘environmentally-preferable’ for cleaning under a state purchasing division attesting to having such a state-wide environmental program.
- This system must be recognized and listed by an environmental organization, such as ‘GREEN SEALS’, as recommended for commercial cleaning. (Both of our system’s components-H2Orange2 and A-Ben-Aqui are both ‘GREEN SEALS’ recommended).(**Contracted as ‘Environmentally-Preferable’ as a cleaning product by the State of Massachusetts—Listed by ‘Green Seals’ as a recommended cleaner.)
- This system must comply with the 1999, jointly-published guideline ‘HEALTHIER CLEANING & MAINTENANCE: PRACTICES AND PRODUCTS FOR SCHOOLS’ by the Healthy School Network and the New York State Association for Superintendents of Buildings and Grounds.
- The system must have the capabilities of being automatically dispensed to guarantee proper usage and so custodial DO NOT have to directly handle products, wherever applicable. In the event that products meet all of the standards and criteria stated above, then, and only then, can be it deemed OFFICIALLY as ‘environmentally-preferable’ (or unofficially ‘environmentally-safe’ or ‘environmentally-friendly’). If not, then the environmental terms attached to the product is nothing more than sales and/or marketing hype.
STAN HALPERN is an environmental cleaning consultant for over 28 years. He advises facility directors, professional cleaning contractors, homeowners, and ‘do-it-yourselfers’ with their cleaning problems each and every day. As an environmental cleaning consultant, he takes great pride in recommending responsible ‘environmentally-preferable’ solutions to facility managers in commercial, school, and public buildings regarding the healthiest and safest ways to address cleaning and maintenance problems in their buildings.
LAURI HALPERN, Stan’s wife, is President and sole owner of ‘HEALTHY CLEAN BUILDINGS’-dedicated to ‘safe cleaning products that care’.